The foreign history and proposed U.S. responsibilities need their own accurate evidence. An old chart does not automatically describe the new assignment.
Track organizational changes honestly
Record changes to authority, staff and business activity. For a new office, use the initial approval period and actual extension evidence rather than assuming a forecast proves later results.
Confirm whether the foreign employment record contains twelve uninterrupted qualifying months within the relevant lookback window and whether any travel or employment change interrupts the story. Keep leases, opening budgets, staffing plan versions, supplier arrangements, entity records, and foreign-company continuity evidence with clear dates. In every case, verify one continuous year abroad within the prior three, the qualifying corporate relationship, continuing foreign business and primarily managerial or executive U.S. duties. A common timing error is filing around a polished future chart while employment agreements or reporting changes still have unresolved effective dates. Build backwards from the date the U.S. operation must begin trading, allow for a request for further evidence, and put the twelve-month extension review in the calendar the day the first petition is filed.